Facts:

The case involves Teo Tiam, a Chinese national and owner of several trucks, who had been granted a license by the Office of Public Works for the year 1939 to operate his vehicles for transportation purposes. In 1940, Tiam sought to renew his license but was informed that he needed to secure a certificate of public convenience from the Public Service Commission (PSC) before the renewal could be processed. The PSC, however, refused to issue the certificate on the grounds that Tiam was a foreigner. Consequently, Tiam filed a petition with the Supreme Court, seeking to compel the Office of Public Works to issue the requested license for 1940 and to require the PSC to provide the necessary certificate of public convenience. The legal framework for this case is rooted in Commonwealth Act No. 146, which defines public service and stipulates the requirements for operating public utilities in the Philippines. The law explicitly includes any person who operates a means of transportatio...

Facts:

1. Ownership and Licensing: The petitioner, Teo Tiam, a Chinese national, owns several trucks licensed by the Office of Public Works for the year 1939, which were used for compensated transportation services.
2. Renewal Request: In 1940, Teo Tiam applied for the renewal of his license with the Office of Public Works. However, he was required to first obtain a certificate of public convenience from the Public Service Commission.
3. Denial of Certificate: The Public Service Commission refused to issue the certificate of public convenience on the grounds that Teo Tiam was a foreigner.
4. Legal Action: Teo Tiam petitioned the court to compel the Office of Public Works to issue the 1940 license and the Public Service Commission to issue the corresponding certificate of public convenience.

Issue:

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Ruling:

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Ratio:

1. Definition of Public Service: Under Section 13 of Commonwealth Act No. 146, as amended, the term "public service" includes any person who owns, operates, or manages in the Philippines, for compensation, any motor vehicle for the transportation of goods or passengers, whether with or without a fixed route. Teo Tiam's trucking business clearly falls under this definition.
2. Requirement of Certificate of Public Convenience: The law mandates that a certificate of public convenience must first be obtained from the Public Service Commission before the Office of Public Works can issue a license. This requirement is a prerequisite and cannot be bypassed.
3. No Vested Right to License Renewal: The license issued by the Office of Public Works is valid only for the current year and must be renewed annually. Teo Tiam cannot claim a vested right to operate his trucks beyond the period covered by the previous license.
4. Constitutional and Statutory Basis for Denial: The denial of the certificate of public convenience to Teo Tiam, as a foreigner, is consistent with Section 8, Article XIII of the Philippine Constitution and Section 16(a) of Commonwealth Act No. 146, which prioritize Filipino citizens in the operation of public services.